(a) The Plaintiff’s claim 1) an promoted mutual savings bank (hereinafter referred to as an “promotion mutual savings bank”) is only a promotion mutual savings bank;

) The Seoul Central District Court filed a suit against B and C for the claim for the takeover amount of the claim against B and C. On January 9, 2009, the said court rendered a decision of performance recommendation that “B and C shall jointly and severally pay to the Plaintiff (Seoul Mutual Savings Bank) the amount of KRW 23,323,597 and KRW 11,396,324 per annum from the day following the date of final delivery of the copy of the complaint to the day of full payment.” The said decision became final and conclusive around that time (hereinafter “the claim against B and C”).

(2) On June 15, 201, an promoted mutual savings bank entered into an asset transfer agreement, including the transfer of the instant claim, on behalf of the Plaintiff, and notified the Plaintiff of the said transfer of claim to B and C on behalf of the promoting mutual savings bank.

3) The instant claim acquired by the Plaintiff is KRW 38,717,975 as of October 21, 2015, which is the date of the closing of argument in the instant case (the total principal and damages for delay until October 21, 2015). (b) When D, the owner of the real estate listed in the separate sheet (hereinafter “instant real estate”) died, the Defendant, children, E, B, and C, who are co-inheritors of D, shall own the instant real estate solely as of March 3, 2010 (hereinafter “instant agreement on the division of inherited property”). Accordingly, the Defendant completed the registration of ownership transfer due to the agreement on the division of inherited property as of October 18, 201, by the registration office of the Gwangju District Court, as of October 18, 2011.

2. B and C, at the time of the agreement on the division of the inherited property of this case, did not have any other assets except the inheritance shares in this case.

C. As to the instant real estate as to the right to collateral security regarding the instant real estate, prior to the agreement on division of the inherited property of this case.